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Designed to provide a practical and up-to-date refresher on the UK AML framework, this workshop has a particular focus on SARs reporting, common pitfalls, and recent developments that materially affect firms but are often overlooked. The emphasis throughout is on operational decision-making, regulatory expectations and lessons from enforcement and supervisory practice.
It is deliberately designed to be highly collaborative and interactive, particularly for MLROs and those performing equivalent roles. That’s why it is an in-person session in order to capitalise on the mutual benefits of bringing experienced financial crime professionals together for an animated discussion about the complexities of suspicious activity reporting.
Rather than a purely lecture-based format, the discussion will draw on participants’ own experiences, judgements and challenges, with facilitated discussion around real-world scenarios and decision points. The aim is to deliver a session in which MLROs can benchmark their approaches, share practical insights and learn from each other’s successes and missteps, as well as from regulatory and law enforcement perspectives.
This peer-led element is intended to reflect the reality that many of the most difficult AML and SARs issues do not have clear-cut answers and are best explored through informed, collective discussion.
best practices for reviewing and filing internal and external SARs
regulatory update and legislative changes, including the Economic Crime and Corporate Transparency Act 2023
practical tips for dealing with regulators and law enforcement.
Quick recap of the UK AML framework
This opening segment provides a structured refresher of the core criminal AML provisions under UK law, setting the foundation for the SARs-focused discussions that follow. It will cover:
the principal money laundering offences under the Proceeds of Crime Act 2002 (POCA), including the distinctions between the primary laundering offences and the regulated sector offences
the scope and mechanics of the failure to disclose offence, including who is caught, what constitutes “knowledge or suspicion”, and the relevance of the appropriate disclosure defence
the offences of tipping off and prejudicing an investigation, including how these risks arise in day-to-day client communications and internal escalation processes
practical examples illustrating how these offences are most commonly engaged in professional services and financial services contexts
the focus will be on clarifying grey areas that frequently cause uncertainty in practice rather than re-stating black-letter law.
Interactivity between these provisions and the UK Money Laundering Regulations
This section explores how the criminal law framework interacts with the preventive regime under the Money Laundering Regulations (MLRs), and where firms often misunderstand the relationship between the two. Topics include:
how the MLRs’ risk-based requirements (CDD, ongoing monitoring, record-keeping) feed into the formation of knowledge or suspicion under POCA
common misconceptions around when regulatory non-compliance does (and does not) translate into criminal exposure
the practical role of MLROs and nominated officers at the intersection of the regulatory and criminal regimes
regulatory expectations on escalation, internal SARs and governance, and how these align with statutory disclosure obligations.
NCA SARs reporting – what can we learn from published statistics on SARs?
Using the NCA’s annual SARs reports and related publications, this segment examines what the available data tells us about how the SARs regime operates in practice. It will cover:
key trends in SARs volumes, reporter sectors and reporting behaviour
insights into SAR quality, including recurring issues highlighted by the NCA
what the statistics reveal about the operational use of SARs by law enforcement
limitations of the published data and what firms should (and should not) infer from it
the aim is to ground SARs decision-making in evidence rather than assumptions.
SARs reporting – what does good look like?
This section focuses on regulatory and law enforcement expectations around high-quality SARs. It will address:
the core characteristics of an effective SAR, including clarity, relevance, and the articulation of suspicion
the importance of narrative structure and the distinction between facts, context and analysis
common hallmarks of SARs that are genuinely useful to law enforcement
practical tips for improving internal processes to support better-quality reporting
examples will be used to illustrate how small drafting choices can materially affect the value of a SAR.
SARs reporting – where can it go wrong?
This extended, practical session examines the most common failure points in SARs reporting and related processes, drawing on enforcement action, supervisory findings and real-world experience. Topics include:
over-reporting versus under-reporting, and the risks associated with both
poorly articulated suspicion, defensive SARs and “data dumps”
timing issues, including late reporting and delays caused by internal governance
tipping off risks arising from client engagement, internal communications and remediation activity
inadequate documentation of decision-making and rationale
sharing “war stories” from practice, including NCA enforcement scenarios, and the practical lessons that follow
This session will be highly practical and scenario-driven, encouraging participants to test their judgement against realistic fact patterns.
Significant AML developments which have flown under the radar
The closing segment highlights important legal and regulatory developments that have not always received sustained attention but have meaningful implications for MLROs and their firms. These include:
recent and forthcoming changes to information-sharing provisions and how they may affect collaboration between firms and law enforcement
developments in the attribution of criminal liability to senior managers and implications for governance and oversight
reforms and proposed reforms to SARs systems and information-sharing mechanisms, including what firms should be doing now to prepare
emerging themes in supervisory and enforcement approaches that may shape future expectations
the session will conclude with a brief discussion of practical takeaways and areas where firms may wish to reassess existing policies and controls.
Partner, Michelman Robinson
Ruth Paley is a leading authority on corporate crime, financial regulation, and investigations, with particular expertise in anti-money laundering (AM...
Ruth Paley is a leading authority on corporate crime, financial regulation, and investigations, with particular expertise in anti-money laundering (AML) and enforcement strategy. Known for her command of the UK Money Laundering Regulations, Ruth is consistently recognised as a top practitioner in her field, “a powerhouse performer in global corporate investigations,” and “one of the leading names in anti-money laundering work in London, with a depth of knowledge few in the City have” (Legal 500).
She acts for global corporates, financial institutions, and senior executives facing exposure to criminal and regulatory risk. Ruth frequently leads internal investigations, large-scale remediations, and regulatory inquiries, working side-by-side with Boards and ExCos to advise on enforcement strategy and risk mitigation. She is often called upon to support firms grappling with criminal activity on the part of employees and third parties, using a solutions-focused approach to protect her clients’ best interests. Ruth also represents individuals under investigation by the SFO, the City of London Police, and other enforcement authorities.
This session is most suitable for those with an existing knowledge of the UK AML regime.
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